In re L.C. CA4/2, E078154

In December 2019 CFS removed L.C. (then 13 months old) after mother reported a third party (“KB”) had the child; L.C. had healing eczema and mother lacked stable housing or a plan.
L.C. was placed with his godmother, Ms. G., who had cared for him intermittently since infancy and was willing to adopt.
Mother received reunification services from January 2020 until June 2021 but did not complete her plan; visits were supervised (weekly, two hours) and became inconsistent.
At the 18-month review reunification services were terminated and a §366.26 hearing was set; the social worker’s §366.26 report recommended adoption and found L.C. adoptable.
At the §366.26 hearing the juvenile court rejected mother’s request to apply the beneficial parent‑child relationship exception and terminated parental rights; T.R., the alleged father, was in the military and not participating in the proceedings.

Issue	Plaintiff's Argument (CFS)	Defendant's Argument (Mother)	Held
Whether the beneficial parent‑child relationship exception (§366.26(c)(1)(B)(i)) applies	Mother did not meet the statutory requirements: visitation was not regular/consistent and the parent‑child relationship did not outweigh adoption	Mother argued she had a positive bond that would make termination detrimental and adoption inappropriate	Court affirmed: substantial evidence supports that mother failed the regular‑visitation prong; exception does not apply; parental rights terminated
Whether mother can challenge alleged father T.R.’s notice/SCRA protections	CFS: mother lacks standing to raise another parent’s notice or SCRA rights; issues forfeited because not raised below	Mother argued T.R. was denied due process and SCRA protections because he was not properly noticed while deployed	Court affirmed: mother lacks standing to assert T.R.’s personal notice/SCRA rights and forfeited the SCRA claim by not raising it earlier

In re Caden C., 11 Cal.5th 614 (California Supreme Court 2021) (articulates three‑part Autumn H. test and hybrid review for beneficial parent‑child exception)
In re Autumn H., 27 Cal.App.4th 567 (Cal. Ct. App. 1994) (established standard for beneficial parent‑child relationship exception)
In re Caitlin B., 78 Cal.App.4th 1190 (Cal. Ct. App. 2000) (mother lacks standing to challenge alleged father’s notice rights)
In re L.A.-O., 73 Cal.App.5th 197 (Cal. Ct. App. 2021) (scope of appellate review limited to evidence before juvenile court at §366.26)
In re Zeth S., 31 Cal.4th 396 (California Supreme Court 2003) (appeal reviews correctness of judgment based on record before trial court)
Diamond Multimedia Sys., Inc. v. Superior Court, 19 Cal.4th 1036 (California Supreme Court 1999) (courts should not rewrite clear statutory language)
In re Eli B., 73 Cal.App.5th 1061 (Cal. Ct. App. 2022) (no need to reach later prongs when regular visitation prong fails)